People vs. Umali (Digest)

G.R. No.
L-5803 November 29, 1954
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NARCISO UMALI, ET AL., defendants.
NARCISO UMALI, EPIFANIO PASUMBAL and ISIDRO CAPINO, defendants-appellants.
TOPIC: Sedition
FACTS: Umali, Pasumbal, and Capino were found guilty by the CFI of Quezon province of the complex crime
of rebellion with multiple murder, frustrated murder, arson and robbery said to have been committed during the
raid staged by armed men in the town of Tiaong, Quezon. The said raid resulted in the burning down and
complete destruction of houses, including that of Mayor Punzalan. Some of the raiders also engaged in looting
and in robbing one house and two Chinese stores until they were dispersed and driven from the town by the
Philippine Army soldiers.
The records revealed that Congressman Umali and Mayor Punzalan were old time friends and belonged to the
same political faction. These friendly relations, however, did not endure. In the elections of 1951, Punzalan ran
for reelection. To oppose him, Umali picked Pasumbal, his trusted leader. Punzalan won. Naturally, Umali and
Pasumbal were keenly disappointed. It appears that on the night before the elections, Umali instructed
Pasumbal to contact the Huks so that Punzalan will be killed. The raid was then carried out by the Huk troops
numbering about 50, armed with garands and carbines. Part of the contingent went in the direction of
Punzalan's house and attacked it with automatic weapons, hand grenades, and even with bottles filled with
gasoline. It was evident that the purpose of the attack on Punzalan's house was to kill him. Fortunately,
however, Punzalan left early that morning to go to Lucena, the capital.
ISSUE: WON the trial court is correct in finding the accused guilty of the complex crime of rebellion with
multiple murder, frustrated murder, arson and robbery
HELD: No.
The Court ruled that the principal and main (though not necessarily the most serious) crime committed here
was not rebellion but rather that of sedition. The purpose of the raid and the act of the raiders in rising publicly
and taking up arms was not exactly against the Government and for the purpose of doing the things defined in
Article 134 of the RPC under rebellion. The raiders did not even attack the Presidencia, the seat of local
Government. Rather, the object was to attain by means of force, intimidation, etc. one object, to wit, to inflict an
act of hate or revenge upon the person or property of a public official, Mayor Punzalan. Under Article 139 of the
same Code, this was sufficient to constitute sedition.
As regards the crime of robbery, it was not one of the purposes of the raid, which was mainly to kidnap or kill
Punzalan and destroy his house. The robberies were actually committed by only some of the raiders,
presumably dissidents, as an afterthought, because of the opportunity offered by the confusion and disorder
resulting from the shooting and the burning of the three houses, the articles being intended presumably to
replenish the supplies of the dissidents in the mountains. For these robberies, only those who actually took part
therein are responsible, and not the three appellants herein.
With respect to the crime of multiple frustrated murder, while the assault upon a policeman with a hand
grenade causing him injuries resulting in his blindness in one eye may be regarded as frustrated murder, the
wounding of five other people should be considered as mere physical injuries.
The crimes committed are, therefore, those of sedition, multiple murder, arson, frustrated murder and
physical injuries. The murders may not be qualified by evident premeditation because the premeditation was
for the killing of Punzalan. The result was the killing of three others intended by the raiders. The killing may,
however, be qualified by treachery, the raiders using firearms against which the victims were defenseless, with
the aggravating circumstance of abuse of superior strength. The three murders may be punished with the
penalty of death. However, because of lack of the necessary votes, the penalty should be life imprisonment.

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G.R. No.

L-5803 November 29, 1954

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